Save the Bala Falls

Summary
Our October 18, 2013 presentation to the Township of Muskoka Lakes Council detailed dangers to in-water recreation of the proposed project, and showed that other hydro-electric generating stations do not have nearby in-water recreation so they do not have the public safety problems the proposed Bala project would have.

The proponent’s only answer is; people shouldn’t be swimming at the base of the Bala North Falls anyways. That is, the proponent refuses to accept that people always have, and always will enjoy summers in the water at the Bala North Falls.

So the proponent has a big public safety problem – as would any organization facilitating this mess of a proposed project.

Now the proponent is requesting to use valuable Township land during construction. We therefore ask “What would the municipality’s liability be for facilitating the construction of this dangerous proposed project”.

Given that the public’s continued access to this Township land is important to the area’s economy, it is clearly best that the Township refuse to help this dangerous proposed project along in any way.

Detail
On October 18, 2013 we had the opportunity to delegate to the Township of Muskoka Lakes Council on the topic of public safety. As detailed in our presentation;

1. The operation of the proposed Bala generating station would be particularly dangerous because:
   1. It would operate in cycled operation an average of 46 days every summer. This means it would start operation at a required flow rate of about 24 m³/s at about noon on more than ⅓ of summer days. It is important to note that during cycled operation, the proposed station would run at about the same flow rate as the full capacity of the Bracebridge Falls Generating Station – which has a large warning sign: Extreme Danger, Keep Out, Swift Currents & Undertow May Occur At Any Time.
       
   2. The proposed Bala generating station would run at full capacity (which would be 96 m³/s – 3½ times that of the Bracebridge Generating Station) an average of 21 days every summer. And note that while most of the flow from Lake Muskoka now enters the Moon River through the Bala South Channel, if the proposed generating station was built, this fast water would be brought 250′ closer to the very popular in-water recreation area at the base of the Bala North Falls.
       
2. Clearly, these are both extremely dangerous conditions, but would only be a risk to public safety if there were people nearby. As shown in our presentation, other hydro-electric generating stations simply do not have people, residences, docks, and boats nearby. But the Bala Falls are unique as they are popular, accessible, and people have always been and will always be nearby in the water.

That is, the Bala Falls are different, and simply not a safe place for a hydro-electric generating station. So our message to Township Council is, protect yourself and the public; don’t let the proponent’s public safety problems become your problems, don’t get involved with this proposed project by facilitating it in any way.

Our previous presentation on public safety is here.

On September 13, 2013, SaveTheBalaFalls.com had the opportunity to present an update to the Township of Muskoka Lakes Council.

The presentation is here.

Additional information provided subsequently follows:

Summary

• The insurance cost cited is from this MNR report.
• The proponent’s dangerous flow simulation shown would occur throughout the year, including many times each summer.
• The required cycling operation would both amplify the lower flows of the summer, and would result in the proposed station’s operation beginning – silently and without warning – just when people would already be in the water. The result would be extreme danger and drownings.
• Despite repeated requests, the proponent has not had an organization competent in swimming safety provide comments or suggestions on their current proposal.

 Detail

1) Concerning the insurance cost cited in this article:

• This information is from this Ministry of Natural Resources’ recent study entitled “Economic Impact of Waterpower Projects on Crown Lands in Ontario”. Section 3.11 Costs, Table 2 (page 5) provides annual operating costs per MW of station capacity, where of the Total Operating Expenditures of $134,000, the Insurance Premium is $75,000.

• I might add that this report carefully tallies economic benefits, but does not present any negative economic impacts, and therefore provides an incomplete and deceptive conclusion. Last year, I therefore sent this letter to the MNR, and received this response. Remarkably, the MNR simply replies that providing a balanced view of the economic impact was “beyond the scope of this project”.

2) Concerning how often the high flow used in the proponent’s flow simulation presented here would actually occur:

Firstly, this flow simulation is from the proponent’s Environmental Screening Report Addendum, released July 20, 2012, and this last page is entitled “Flow Velocity Field, Downstream Channel, Post Development, Q=98 cms”. This flow therefore represents the proposed generating station operating at full capacity, as confirmed by Section 2.1.2 of this Addendum.

Since February 2013, SaveTheBalaFalls.com has had an analysis of the Moon River water flow posted here, some conclusions from this and the proponent’s information provided are as follows:

a) While the average flow through the generating station in the summer months is typically low, it would be amplified by the required cycling operation:

• For example, Section 2.1.6.1 (page 2-5) and Figure 2.4 of the proponent’s 2009 Environmental Screening Report shows that the flow through the Bala North Falls is typically less than 10 m³/s during the summer months (as any excess water now flows through the Bala South channel). However, the proponent would be required to operate the proposed generating station in a cycling mode operation during low flow periods “such that its operating discharge is 26 cms or more” (according to the December 15, 2010 signed agreement with Ontario Power Generation). Therefore, the flow at the base of the Bala North Falls would be increased during plant operation from less than 10 m³/s to more than 25 m³/s – an increase by a factor of more than 2½.

• And shown in “Detail – Cycling Operation” here, this cycling operation would occur for about ⅓ of summer days, with operation beginning soon after 11:00 am on those days (which would be the most likely time for people to be in the water near the tailrace of the proposed station).

Therefore, this substantial increase in flow would occur often enough to be significantly dangerous.

b) Operation at the station’s full capacity is shown in “Detail – Running at Full Capacity” here:

• It shows that during the 44 years of historical water flow data available, the station would have run at full capacity at least ten times during most every week of the year – even the summer weeks.

• Specific analysis is provided for the most recent years the data was available, including that the station would have run at full capacity in 2009 both until May 25 and from July 31 to August 3. In 2008 the station would have run at full capacity; to May 26, from June 10 to June 25, from July 4 to 6, from August 12 to 20, and from September 16 to 22. And in 2007 the station would have run at full capacity to May 6, and from July 21 to 22.

That is, the station would operate at full capacity, as shown in the proponent’s flow simulation, many times each summer. So the drowning danger would be present often enough to be significant.

As noted, this information has been posted on the SaveTheBalaFalls.com website for over six months and we have not received any concerns about its accuracy. As always, contact us at info@SaveTheBalaFalls.com to discuss this data, the calculations, or anything else on the website.

3) Concerning our claim that drowning would result from the proposed station’s tailrace being so close to the in-water recreational area at the base of the Bala North Falls:

To begin with an example, I don’t think one needs any particular qualification other than some common sense to say that children should not play on the shoulder beside a busy highway.

1. Further, when the proposed station is operating at full capacity (often enough, as noted above) the speed of the water from the tailrace would be faster than an Olympic swimmer can swim – as is noted here. Given the water exiting the station’s tailrace would be churning and turbulent due to the station’s turbine rotation, I think it is common sense that even when operating at less than full capacity, for example at the 26% for the required cycling operation, people would still drown in this fast water which would be just feet from where people would be swimming.
2. I should note that despite repeated requests, the proponent has never had an organization competent in swimming safety provide any suggestions, concerns or advice about their proposals. I would be happy to defer to such input.
3. Given the proponent’s extremely biased view, unsubstantiated assurances of safety from them should be ignored.
4. I should also note that as provided by the example of the Moon River Property Owners Association’s concerns that known rocks and shoals in the Moon River are not marked, there is no organization responsible for public safety. As the Township of Muskoka Lakes would be the most affected by drownings due to the proposed station, it would be in the Township’s interest to pursue their own confirmation of public safety independent of the proponent.

It is clear that the proponent’s current proposal (“Alternative 1A”) would:

1. Be more difficult, and cost more, to build
   • Would require a temporary construction bridge over the north falls, construction materials would need to be stored farther away, site excavation and hauling more difficult
2. Produce less power
   • Because of the constricted intake, which also has more bends
3. Cost more to operate
   • Maintenance access, driveway access, and intake gate implementation would be more difficult, transformer location and ventilation more difficult
4. Impinge on riparian rights and right of navigation
   • For at least the three private property owners and for the Township of Muskoka Lakes dock, just downstream
5. Create massive dangers to the public
   • Due to the long-time and very popular in-water recreation within 50′ both upstream and downstream

So if it would cost more to build and operate, produce less power, and have operational risks, why did this happen.

Firstly, the proponent simply would not actually provide answers to the public’s fair and relevant questions, so the Township of Muskoka Lakes could not proceed with land lease negotiations, so the proponent could not proceed with their proposed Option 2. As the proponent chose to not answer the questions, presumably they knew the public would not like the answers.

As to why such an unworkable proposal is now being considered, it appears the government’s attitude is “if you want to build such a ridiculous thing, we’ll rubber-stamp the approval”.

Finally, the Ontario Liberal government’s process is backwards in that they first select an “Applicant of Record” and the government then considers they have an obligation to approve whatever the proponent then proposes, even if it is then found that there are environmental or other problems. The government apparently feels they have a committment that once a proponent starts spending money on environmental assessment and other design and approval work, the proposed project must be approved, both so:

• The government has no liability for money spent by the proponent (which would be wasted if approvals are not granted).
• That private developers will continue to finance and build generating stations in the future.

The end result is that the environmental assessment process becomes a meaningless farce. So here we are, with a proponent trying to build something that shouldn’t be built.

Did you know that insurance is the largest operating cost of hydro-electric generating stations – larger than all other operating costs combined, including maintenance, administration, depreciation, and taxes.

Visiting the nearby hydro-electric generating stations; Hanna Chute (Bracebridge), Matthias Falls (Bracebridge), Minden, Muskoka South Falls (Bracebridge), Trethewey Falls (Bracebridge), Bracebridge Falls, Wilson’s Falls (Bracebridge), High Falls (Bracebridge), Big Eddy (Bala), Ragged Rapids (Bala), Wasdell Falls (Severn Bridge, planned), Fenelon Falls, Auburn (Peterborough), London Street (Peterborough), Shand Dam (Fergus), Elliot Falls (Norland), and Heywood (St. Catherines) shows that:

• NONE have in-water recreation both upstream and downstream within 50′ – but Bala does.
• NONE have public and private boat docks within 200′ – but Bala does.
• NONE have private residences within 200′ – but Bala does.
• NONE are the focal point for visitors – but it is in Bala.

That is, the Bala Falls is a different situation than all others. It is accessible and constantly visited by loads of people.

The Ministry of Natural Resources is not accepting that the Bala Falls is different. Not only the proximity to in-water recreation, but also the required – and treacherous – cycling operation. This proposed hydro-electric generating station would be an accident waiting to happen – again and again.

For over 100 years, families have splashed and played at the base of the Bala Falls. This proposed project would bring the fast water that currently enters the Moon River through the South Channel 250′ closer to this. As a result, people will drown. And the proponent building this ill-advised project would be complicit in these deaths.

We sent the letter below to Premier Wynne on September 11, 2013 …

Hello Premier Wynne,

Since I met with you last year concerning the proposed hydro-electric generating station at the Bala Falls, the proponent has presented a new proposal which would:

• Be outrageously dangerous to vacationing families
• Result in drownings, and therefore lawsuits and liability to the province

 Further details are in the attached letter, please respond with what actions you will take.

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Mitchell Shnier, on behalf of SaveTheBalaFalls.com
℅ Box 346
1038 Bala Falls Road
Bala, ON  P0C 1A0